in the Interest of J.A. Child v. Department of Family and Protective Services

CourtCourt of Appeals of Texas
DecidedMarch 17, 2022
Docket01-21-00606-CV
StatusPublished

This text of in the Interest of J.A. Child v. Department of Family and Protective Services (in the Interest of J.A. Child v. Department of Family and Protective Services) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
in the Interest of J.A. Child v. Department of Family and Protective Services, (Tex. Ct. App. 2022).

Opinion

Opinion issued March 17, 2022

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-21-00606-CV ——————————— IN THE INTEREST OF J.A., A CHILD

On Appeal from the 314th District Court Harris County, Texas Trial Court Case No. 2020-00787J

MEMORANDUM OPINION

After a bench trial, the trial court entered a decree terminating the mother’s

and father’s parental rights with respect to their son, J.A. On appeal, the mother contends that the trial court committed reversible error because the evidence is

legally and factually insufficient to support the termination of her parental rights.1

We affirm.

BACKGROUND

J.A. was born in October 2019. The Texas Department of Family and

Protective Services received a referral the day he was born because his mother, the

appellant, tested positive for amphetamines at the hospital.

The Department later sought termination of the appellant’s parental rights as

to her son on two grounds: (1) constructive abandonment and (2) failure to comply

with the terms of her court-ordered family service plan.

The suit was tried to the bench. The appellant was not present for trial, and

the appellant’s counsel was unable to get in contact with her. Two witnesses

testified: the caseworker assigned to the child and the child’s foster mother.

Angela Molina was the assigned caseworker. She testified that J.A. was

almost two years old at the time of trial. According to Molina, J.A. first came into

the Department’s care because his mother had another open Child Protective

Services case and had drugs in her system when J.A. was born.

1 The trial court terminated the parental rights between J.A. and his alleged father, whose paternity had not been established as of the time of trial, as well as any unknown father’s rights. The parental rights of any ostensible father are not at issue in this appeal. 2 Molina testified that the Department had provided the appellant a family

service plan, which included requirements that she undergo substance-abuse and

psychological assessments, maintain stable income and housing, sign a release for

the disclosure of certain information, and visit her child. However, the appellant did

not complete the substance-abuse assessment. In addition, the appellant did not show

that she had stable housing or was employed. Molina testified that the appellant had

told her that she was moving from shelter to shelter. That is, the appellant was

homeless. Molina testified that the appellant did not complete her service plan in

general. The appellant also had not inquired as to what she could do to complete her

plan. In contrast, Molina testified, the Department had done what it could to facilitate

the services that the appellant had been ordered to complete.

Molina further testified that the appellant had not seen J.A. since last year,

when a previous caseworker had been assigned to the child. Trial took place in late

August 2021. The appellant had not seen J.A. at all that year. According to Molina,

the appellant had not maintained continuous or significant contact with her son since

he came into the Department’s care. Molina stated that she had no reliable way of

contacting the appellant. Thus, Molina indicated, she had to wait until the appellant

contacted her.

At the time of trial, J.A. resided with a foster family who had recently adopted

his older brother. Molina stated that J.A. is thriving with his foster family and

3 meeting all his developmental milestones. J.A. has an excellent bond with his brother

and is very attached to his foster parents.

Molina testified that the Department was requesting that the court terminate

the appellant’s parental rights on two grounds: the appellant had not maintained

contact with J.A., and she had not completed her family service plan. Molina further

testified that termination of the appellant’s parental rights was in J.A.’s best interest.

According to Molina, the Department’s current plan was for J.A.’s foster family to

adopt him after termination.

J.A.’s foster mother testified that she had adopted his older brother three years

before when the appellant’s rights had been terminated in that case.

J.A. had been residing in his foster mother’s home since May 2020. His foster

mother testified that he was doing great there, was developing well, and had bonded

with his brother. She testified that the last time the appellant had visited J.A. was in

August 2020 via a virtual meeting for an hour. The appellant never tried to arrange

to visit J.A. again afterward.

J.A.’s foster mother testified that she and her husband intend to adopt the child

if he becomes available for adoption. She testified that they want J.A. and his

brother, whom they have already adopted, to remain together.

The trial court entered a decree terminating the appellant’s parental rights as

to J.A. It found two independent grounds for termination of the appellant’s parental

4 rights, specifically that she constructively abandoned her son and failed to complete

her court-ordered family service plan. See TEX. FAM. CODE § 161.001(b)(1)(N)–(O).

The trial court also found that the appellant had neither alleged nor proved a defense

of inability to comply with her family service plan or that she had in good faith tried

to comply with her family service plan. Finally, the trial court found that the

termination of the appellant’s parental rights was in her son’s best interest. See id.

§ 161.001(b)(2).

DISCUSSION

The appellant contends the evidence is legally and factually insufficient to

show she constructively abandoned her son or failed to complete her court-ordered

family service plan. She also contends the evidence is legally and factually

insufficient to show that termination of her rights is in her son’s best interest.

Legal Standard for Terminating Parental Rights

A parent’s rights to the care, custody, and management of his or her child are

constitutional in scope. Santosky v. Kramer, 455 U.S. 745, 758–59 (1982); In re

M.S., 115 S.W.3d 534, 547 (Tex. 2003). But parental rights are not absolute; the

Department may seek termination of the rights of those who are not fit to accept the

responsibilities of parenthood. In re A.V., 113 S.W.3d 355, 361 (Tex. 2003). The

primary focus in a termination suit is protecting the child’s best interest. Id.

5 To terminate parental rights under the Family Code, the Department must

establish that a parent committed one or more statutorily enumerated predicate acts

or omissions and that termination is in the child’s best interest. FAM.

§ 161.001(b)(1)–(2). The Department need only establish one of these statutorily

enumerated predicate acts or omissions, along with the best-interest finding. See id.;

In re A.V., 113 S.W.3d at 362. But the Department must make these showings by

clear and convincing evidence. FAM. § 161.001(b). Clear and convincing evidence

is “proof that will produce in the mind of the trier of fact a firm belief or conviction

as to the truth of the allegations sought to be established.” Id. § 101.007.

Section 161.001(b)(2)’s best-interest finding is a separate inquiry from section

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